Facebook, Inc. v. Phoenix Media/Communications Group, Inc. et al

Filing 69

DECLARATION re 67 Memorandum in Opposition to Motion by Facebook, Inc.. (Attachments: # 1 Exhibit A)(Chen, Reuben)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
FACEBOOK, INC,
Plaintiff,

C.A. No. 1:10-cv-11917-DPW

PHOENIX MEDIA/COMMUNICATIONS
GROUP, INC., PEOPLE2PEOPLE GROUP,
INC., TELE-PUBLISHING, INC., AND FNX
BROADCASTING LLC,

JURY TRIAL DEMANDED

v.

Defendants.

DECLARATION OF REUBEN H. CHEN IN SUPPORT OF
FACEBOOK, INC.’S RESPONSE TO PHOENIX MEDIA/
COMMUNICATIONS GROUP, INC. AND PEOPLE2PEOPLE GROUP, INC.’S
STATEMENT OF MATERIAL FACTS

I, Reuben H. Chen, declare as follows:
I am an attorney at the law firm of Cooley LLP. I represent the Plaintiff Facebook, Inc.
(“Facebook”) in the above captioned matter and have been admitted pro hac vice to this Court.
I make this declaration in support of Facebook’s Response to Phoenix Media/Communications
Group, Inc. and People2People Group, Inc.’s Statement of Material Facts in support of their
Motion for Summary Judgment.
1.

Attached hereto as Exhibit A is a true and correct copy of an Applied Materials

Interoffice Correspondence bearing Bates numbers FBPMC00000484-486.

I declare under the penalty of perjury under the laws of the United States of America that

1

the foregoing is true and correct. Executed this 2nd day of September, 2011 at Palo Alto,
California.

/s/ Reuben H. Chen
Reuben H. Chen

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CERTIFICATE OF SERVICE
I, Reuben H. Chen, hereby certify that pursuant to Local Rule 5.4(C), this document has
been filed through the ECF system and will be sent electronically to the registered participants as
identified on the Notice of Electronic Filing (NEF). For those parties indicated as non-registered
participants, if any, a paper copy will be sent by facsimile and/or U.S. First Class Mail on
September 2, 2011.
/s/ Reuben H. Chen
Reuben H. Chen

968514 /HN

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